Extra-judicial confession may sustain conviction when voluntary and corroborated by recoveries, disclosures, and surrounding circumstances.

A conviction under the Wildlife (Protection) Act, 1972 can be sustained on a co-accused's extra-judicial confession when the confession is voluntary and is corroborated by other reliable material. The Court treated the custody-recorded confession, the witness who transcribed it, earlier disclosures, material recoveries, and surrounding circumstances as adequate support, including the accused's linkage to an organised wildlife-poaching network and prior involvement in similar offences. On that combined evidentiary basis, the challenge to the findings of guilt failed and the conviction was upheld.

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Issues: Whether the appellant's conviction for offences under the Wildlife (Protection) Act, 1972 was sustainable on the basis of the extra-judicial confession of a co-accused, corroborated by other evidence on record.

Analysis: The appellant was shown to be part of an organised wildlife-poaching network operating through multiple connected cases and recoveries. The co-accused's confession was recorded in custody, was supported by the testimony of the witness who wrote it down, and was corroborated by earlier disclosures and material recoveries. The surrounding circumstances and the appellant's past involvement in similar offences supplied further corroboration. The confession was found voluntary and not obtained by inducement, threat or promise, and there was no legal bar to acting upon it when supported by other reliable material.

Conclusion: The conviction was upheld and the challenge to the findings of guilt failed.

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